HUBX as a Data Processor
A person uploaded as a Contact or Investor is the client’s data subject, and the client is the data controller. HUBX is the data processor for processing activities performed through its web and mobile solutions.
HUBX & GDPR
On May 25, 2018, the European Union’s General Data Protection Regulation came into force. HUBX states that it has worked to ensure compliance and high standards for protecting data, and explains its data roles and responsibilities for clients.
Transferring Data
HUBX states that the written controller-processor relationship under Article 28 is defined in its Privacy Policy and accepted by clients when they first access the platform.
HUBX as Data Controller
In some situations HUBX is the data controller for personal data collected about directly registered users. It cites GDPR Articles 6(1)(b), 6(1)(c), and 6(1)(f).
How is HUBX committed to GDPR?
Internal Processes & Security
HUBX states it has Chinese walls and ringfences for client data, supports GDPR auditing and mapping, and limits access through procedures and audit trails.
Access Requests
HUBX states that its systems can handle requests to delete, change, or transfer client data, with Client Coverage, developers, and engineers available during office hours.
Documentation & Training
User Terms and the Privacy Policy form the legal relationship after registration. Onboarding and ongoing training cover data privacy and security; client-facing staff are stated to be CISI qualified and FCA-approved persons.
Questions or comments?
Email team@hubx.capital.